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Item 12 Staff Report

Palo Alto City Council
May 18, 2026

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Item 12 Staff Report
Meeting
May 18, 2026
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Palo Alto City Council
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CITY COUNCIL
Staff Report
From: City Manager
Report Type: CONSENT CALENDAR
Lead Department: Planning and Development Services
Meeting Date: May 18, 2026
Report #: 2603-6103
TITLE
PUBLIC HEARING / QUASI-JUDICIAL. 4103 Old Trace Road [25PLN-00298]: Request for Approval of a Tentative Map to Allow for the Subdivision of a Vacant 1.02-Acre Lot to Create Nine Residential Lots and One Private Street to Facilitate Construction of Nine New Single-Family Residences and Seven Junior Accessory Dwelling Units (25PLN-00296). CEQA Status: Exempt Pursuant to Assembly Bill 130 (Public Resources Code Section 21080.66). Zone District: RE (Residential Estate)

RECOMMENDATION
Staff recommends that Council take all of the following actions:

1. Consider the project exempt from the California Environmental Quality Act (CEQA) in accordance with Assembly Bill 130 (Public Resources Code section 21080.66); and,

2. Approve the Tentative Map application pursuant to findings and subject to conditions of approval set forth in Attachment B.

EXECUTIVE SUMMARY
The applicant requests approval of a Tentative Map to allow the subdivision of a vacant 1.02- acre parcel into nine (9) residential lots served by a new private street located at 4103 Old Trace Road. Through a separate, Streamlined Housing Development Review (SHDR) application, the applicant proposes to construct five detached single-family residences with Junior Accessory Dwelling Units (JADUs), two attached single-family residences with JADUs, and two attached single-family residences (without any accessory units) for a total of 16 units. The attached single-family residence on Lot 9 is proposed at below market rate, made affordable to moderate income households earning no more than 100% of the Area Median Income (AMI).

The project is exempt from CEQA pursuant to Assembly Bill (AB) 130 for Qualifying Infill Housing Projects and is proposed in accordance with State Density Bonus Law.

BACKGROUND
The proposed application is a request from Steel Bridge Homes Palo Alto for approval of a Tentative Map to subdivide a vacant 1.02-acre lot into nine (9) residential lots served by a new private street (designated as Lot 10 in the proposed plans) located at 4103 Old Trace Road.

Through a separate, Streamlined Housing Development Review (SHDR) application, the applicant proposes to construct five detached and two attached single-family residences, each with JADUs, as well as two attached single-family residences for a total of 16 units. One of the single-family residences is a bonus unit under State Density Bonus law. The applicant is proposing one unit at below market rate made affordable to moderate income households earning no more than 100% of the Area Median Income (AMI).

The map also includes the offer of dedication for proposed drainage and public utility easements, which are required per the City of Palo Alto Utility and Public Works Engineering Department standards. A private street is proposed on the map to serve the proposed residences. A location map is included in Attachment A. A link to the proposed Tentative Map is included in Attachment G.

Requested Entitlements, Findings, and Purview:

The following discretionary applications are being requested:
Tentative Map and Final Map for lot subdivision purposes: The process for evaluating this type of application is set forth in Title 21 of the Palo Alto Municipal Code (PAMC) and California Government Code 66452. The process for approval of a Tentative Map for a lot subdivision is outlined in PAMC Section 21.12.090. Tentative maps require Planning and Transportation Commission (PTC) review. The PTC reviews and makes a recommendation on whether the proposed subdivision is consistent with the Subdivision Map Act (Government Code 66474), Title 21 of the PAMC, the Palo Alto Comprehensive Plan, and other applicable provisions of the PAMC and State law. The PTC’s recommendation is forwarded to the City Council for final approval.

Council’s discretion over the formal application is limited by the following State laws:
Housing Accountability Act (Government Code 65589.5): The project constitutes a “housing development project” under the Housing Accountability Act. The Housing Accountability Act Section 65589.5(j) requires that when a proposed housing development project complies with applicable, objective general plan and zoning standards, a local agency may only deny or reduce the density the project or reduce its density if the agency first finds that, (1) the development would have a specific adverse impact on public health or safety unless disapproved, or approved at a lower density; and (2) there is no feasible method to satisfactorily mitigate or avoid the specific adverse impact, other than the disapproval, or approval at a lower density. For purposes of the Housing Accountability Act, the receipt of a density bonus, incentive, concession, waiver, or reduction of development standards shall not constitute a valid basis on which to find a proposed housing development project is inconsistent with objective standards.
State Density Bonus Law (Government Code Section 65915): State density bonus law defines “base density” to mean the greatest density permitted in either the zoning code or general plan land use designation, including the top of the range, when a range of densities is provided. In addition, when an applicant agrees to provide a specified percentage of units at affordable prices/rents, the applicant is entitled to unlimited waivers of development standards that physically preclude the project and a number of concessions/incentives that result in actual and identifiable cost reductions. Senate Bill (SB) 330 (Government Code Section 65943): California SB 330 (Housing Crisis Act of 2019) allows applicants to freeze local standards at the time a compliant pre- application is submitted and limits the number of public hearings of housing projects to five hearings. SB 330 requires a formal submittal to be provided within 180 days of filing the pre-application.
State ADU Law (California Government Code Sections 66314-66331): This State code establishes a statewide baseline for how cities and counties in California may regulate ADUs by local ordinance and what ADUs/JADUs must be approved regardless of conflicting local regulations. It authorizes ADUs on lots zoned for single-family or multi- family residential use with an existing or proposed dwelling; permits separate rental while generally prohibiting separate sales of ADUs/JADUs except where ADU sales provisions apply; and sets size limits for detached and attached ADUs and JADUs. It also restricts conditioning approval on correcting unrelated nonconformities, limits sprinkler triggers and requires rentals for a period greater than 30 days (i.e., restricts short-term rentals). State law requires that proposals to construct ADUs/JADUs be considered ministerially; even when an ADU/JADU is proposed as part of a larger project subject to discretionary review, the ADU/JADU must be considered separately and ministerially after the discretionary review is complete.

A separate SHDR application is proposed. The process for evaluating this type of application is set forth in PAMC Section 18.77.073. SHDR applications require a study session with the Architectural Review Board (ARB) and recommendations are forwarded to the Planning & Development Services Director for action following the review. Action by the Director is appealable to the City Council if filed within 14 days of the decision. Pursuant to PAMC Section

18.40.170, the Director may also defer to a final decision to City Council. Streamlined Housing projects are evaluated against specific findings. Both of the findings must be made in the affirmative to approve the project. Failure to make any one finding requires project re-design or denial.

Neighborhood Setting and Character
The project is located on Old Trace Road in the Esther Clark Park neighborhood and is surrounded on the east, west, and south by single-family residences within the Residential Estate (RE) zone district. To the north of the property is a research facility and office within the Research Park zone district. Surrounding development is primarily two-story. The site is located near research facilities to the west and four public schools within one mile distance to the east.

ANALYSIS
The proposed project currently under consideration, and relevant discussion and findings herein, reflect the Tentative Map, not the new houses proposed to be built on the proposed parcels. Staff is currently reviewing the associated SHDR application for construction of the proposed housing units. The map does include dedication of relevant public utility and drainage easements associated with the new development.

On April 29, 2026, the PTC considered the Tentative Map and voted unanimously to recommend approval to Council with minor edits to the tentative map findings and to the conditions of approval, as follows:
Ensure that condition #4 requires deed restriction for a BMR unit; Consider allowing public participation in street naming as described in condition of approval #6;
Ensure Conditions #8, and 41-48 include all transportation improvements; Ensure Conditions #50 and 51 are consistent with Public Works recommendations; Include a requirement for a Construction Management Plan for the construction of future housing;
The PTC also recommended the following for Council’s consideration:
Consider future investigation and development of fire safety standards to protect against impacts on adjacent neighbors;
Consider future update to parking requirements for guests and ADUs; Consider other regulations to address cumulative/compounding impacts on neighbors; and
Consider reduction in maximum density allowed for this area under the Comprehensive Plan.

The PTC discussed cumulative impacts of the proposed housing development on existing neighborhood circulation and safety concerns. They expressed concern about potential unintended consequences of these improvements, including drivers attempting to turn right from Arastradero Road onto the private street despite the no-right-turn restriction, which could slow traffic, and the possibility that red-striping along the Old Trace Road frontage could shift parking impacts farther into Old Trace Road. As an alternative to the proposed two-way private street, the PTC discussed the possibility of a one-way private street configuration. However, based on the applicant’s traffic analysis, a one-way private street operating from Old Trace Road to Arastradero Road, combined with the existing median on Arastradero Road, would not allow residents of the new development to make left turns onto Arastradero Road. Instead, westbound traffic would be required to exit onto Arastradero Road and continue to the next location where a U-turn is permitted; however, U-turns are not allowed at the Foothill Expressway intersection.

Additional comments focused on whether the proposed subdivision and associated housing development would disrupt the area’s semi-rural character and preserve the scenic views along Arastradero Road, one of the City’s scenic gateways. The Commissioners emphasized that safety issues should be further evaluated by Council in the context of the broader community, not just within the project boundaries, particularly with respect to objective fire and safety standards, access and circulation on the private street and Arastradero Road, neighborhood ingress and egress on Old Trace Road, and guest parking on the subject site.

Summary of Response to PTC Comments
Conditions #4 requires deed restriction of the affordable housing unit in accordance with State Density Bonus Law and the City’s affordable housing requirements. Condition #6 has been updated to require that PAHA consider any recommendations submitted by residents for the naming of the private street. Historically, the Palo Alto Historical Association has been open to considering any suggestions submitted for the name; though, ultimately, the selected name is reflective of historical research of the property or area. Conditions #8 and 41-48 include all transportation improvements. Conditions #50 and 51 are consistent with Public Works recommendations. Condition #52 has been added to note that the Stormwater Management Plan will be finalized at the time of the SHDR application. A construction management/logistics plan will be required as a condition of approval for the SHDR application per the City’s standard conditions of approval for a development.

Additional recommendations from the PTC are intended for Council’s consideration to modify existing City plans and/or standards.

Consistency with the Comprehensive Plan, Area Plans, and Guidelines1 The proposed Tentative Map is consistent with the Comprehensive Plan, in that the land use designation for the property is “Single Family Residential”, which allows for detached single- family residential uses, as is currently proposed for each resulting parcel. Net densities ranging from 1-7 units per acre and can increase up to 14 units per acre on parcels that include a second unit or a duplex. Pursuant to State Density Bonus Law, the Comprehensive Plan results in a base density of eight units for this parcel,2 consistent with the proposed density prior to density bonus and JADUs.
1 The Palo Alto Comprehensive Plan is available online: http://bit.ly/PACompPlan2030 2 “Base density” means the greatest number of units allowed under the zoning ordinance, or land use element of the general plan, or, if a range of density is permitted, means the highest density in that range. In addition, all 5 The proposed map facilitates development of a vacant parcel within the City’s urban service area which is consistent with Policy L-1.3 wherein, “infill development shall be compatible with its surroundings and the overall scale and character of the city.” Moreover, the proposed project complies with Housing Element Policy 3.2 to, “provide adequate sites, zoned at appropriate densities and development standards to facilitate both affordable and market-rate housing production.” The findings for approval of the subdivision map in Attachment B include a complete analysis of the project’s consistency with the relevant Comprehensive Plan policies.

Zoning Consistency6
The site is zoned RE (Residential Estate). The project includes single-family use of each resulting lot, which is a permitted use within the RE zone district. As allowed pursuant to ADU law, JADUs are proposed on seven of the nine resulting lots as accessory uses to the primary dwelling units.

These units do not count toward maximum density and may be constructed in accordance with the provisions pursuant to ADU law under California Government Code Sections 66314 through 66331 and the City’s ADU regulations as set forth in PAMC Chapter 18.09.

Attachment C includes a summary of the Tentative Map’s consistency with zoning development standards, including the base RE zoning standards, as they relate to the lots to be created.

Pursuant to State Density Bonus Law, the City must grant any number of development waivers needed to avoid standards that would physically preclude the project at the allowed density.

Under State Density Bonus Law, the City may request reasonable documentation to confirm eligibility but may not require a new study or report. The City bears the burden of identifying a valid basis to deny a concession or waiver. For concessions, the City may request documentation showing that the requested concession results in a cost reduction. For waivers, the City may request documentation explaining how the standard would otherwise physically prevent construction at the proposed density.

The application includes the following waiver requests related to the approval of the Tentative Map:7

1.Lot Size: Reduce the minimum lot size as set forth in the RE zone and Title 21 from one acre (PAMC Section 18.10.040(a), Table 2) and 6,000 square feet (PAMC Section

21.20.100), to allow for proposed lots to range in size from 1,570 square feet to 6,907 square feet.

2.Setback: Reduce the special setback on Arastradero Road from 53 feet to:
9 feet, 6 inches, on Lot 5; and
calculations under State Density Bonus law are rounded up to the next whole number. The Comprehensive Plan Land Use designation allows up to seven units per acre; 7 du/ac * 1.02 ac = 7.14 du, which is rounded up to 8 units. 6 The Palo Alto Zoning Code is available online: https://bit.ly/PAZoningCode 7 Additional waivers are required for the SHDR application and are detailed in Attachment F. 15 feet on Lots 6 and 9.

3.Street width: Reduce the minimum width of the private street from 32 feet (PAMC Section 21.20.024 (b)(4)) to 20 feet.

4.Site depth: Reduce the minimum site depth from 100 feet (PAMC Section 18.10.040 (a), Table 2) to 59 feet.

With respect to the setback on Arastradero Road, staff research indicates that it is possible that at the time this special setback was established, the setback may have been measured from the centerline of the street. Nevertheless, the special setback under the current code provisions is measured from the edge of the drainage easement on Arastradero Road. Therefore, although no setback is proposed for Lots 6 and 9, when measured from the drainage easement, the physical improvements on those properties would be set back 15 feet from Arastradero Road.

The applicant’s project description is provided in Attachment F and includes a list of requested waivers and concessions in accordance with State Density Bonus Law and the justification for the requests. As detailed further in this report, if the project is designed to comply with all relevant development regulations, after application of density bons incentives, concessions and waivers, the City cannot impose conditions that would preclude construction of the project as proposed.

Multi-Modal Access
Vehicular Circulation
The project site is currently vacant and has no existing curb cuts. The project proposes a new 20-foot-wide private street to provide access to the residential lots. Although the proposed private street width does not meet the 32-foot minimum required by PAMC Section 21.20.240, the applicant has requested a waiver from this development standard pursuant to State Density Bonus Law. As documented in the traffic study provided in Attachment E, the proposed street width would accommodate the turning movements of passenger vehicles, emergency vehicles, and refuse trucks.

Although a single driveway connection from Old Trace Road would be preferable from a pedestrian and bicycle safety perspective (i.e. eliminating the curb cut on Arastradero Road), the proposed through-access configuration would improve on-site circulation and better accommodate emergency vehicles and refuse collection operations. Without the connection to Arastradero Road, refuse service would need to be staged along the Old Trace Road frontage rather than serviced in front of the individual residences/lots. The curbs along the private street would be painted red to designate a fire lane to support fire apparatus and staging and maintain unobstructed access for emergency vehicles.

Due to the reduced width of the private street, staff identified a potential conflict point for vehicles turning into the new private street from Arastradero Road. In response to concerns raised by the ARB and public commenters at the March 5, 2026, ARB study session, the applicant revised the map to restrict right-turn movements from Arastradero Road into the new private street. This restriction would be implemented through a reduced curb radius design to physically restrict right-turn movements, in conjunction with proper signage and striping at the west corner of the Arastradero Road entrance.

Driveway Configuration and Parking
The project shows individual driveways for Lots 1, 4, and 5 and shared driveways for Lots 2, 3, and 6 through 9. The private access easements for shared driveways will either be reflected on the Final Map or recorded through separate instrument in conjunction with the Final Map, as reflected in the conditions of approval. Parking configurations for each lot would be clarified as a part of the SHDR application and are anticipated to comply with the City’s parking regulations set forth in PAMC Chapter 18.52.

Parking configurations for each lot would be clarified as a part of the SHDR application and are anticipated to comply with the City’s parking regulations set forth in PAMC Chapter 18.52. The Municipal Code requires two parking spaces per single-family unit, including at least one covered space and one uncovered space. No visitor parking is required or proposed as a part of this project. Although the applicant is encouraged to consider providing additional parking for guests as part of the project design under the SHDR application, particularly in response to neighbor comments, there is no code requirement to provide guest parking in the code.

Emergency Vehicle Access
Per the recommendation of the Office of Transportation (OOT) and Public Works Department, the applicant is evaluating parking restrictions along one or both sides of Old Trace Road adjacent to the project site. This would prevent on-street parking from impeding emergency vehicles and refuse truck access to the private street (as shown in the transportation analysis) in addition to addressing an existing condition raised by commenters at the ARB hearing, which noted that when cars are parked on Old Trace Road near Arastradero Road, access for certain emergency vehicles may be temporarily restricted. It should also be noted that parking within 20 feet of the approach side of any marked or unmarked crosswalk is already prohibited under California's Daylighting Law (Assembly Bill 413, California Vehicle Code 22500(n)), which took effect January 1, 2024, and has been fully enforceable since January 1, 2025. As such, parking within the 20- foot approach is not permitted under state law, regardless of curb markings or signage. The proposed red curb markings will provide clear delineation of this existing legal restriction, ensuring drivers are aware of parking restrictions. The applicant is coordinating with both departments and the project civil engineer regarding installation of red curb markings and/or signage along the Old Trace Road frontage.

It is important to note that the existing curb to curb condition on Old Trace Road is 30 feet, with parking allowed on both sides and no sidewalk. The proposed curb-to-curb width would be maintained, with parking now restricted on Old Trace Road between Arastradero and the new private street, and the addition of a sidewalk adjacent the 4103 Old Trace Road property beyond that 30-foot curb-to-curb. Therefore, the project addresses an existing safety condition raised by residents about emergency vehicles access and adds pedestrian improvements, which improve emergency vehicle access in comparison to existing conditions.

Bicycle and Pedestrian Improvements
The project proposes new bicycle lane markings along the existing bikeway on Arastradero Road, including green pavement markings at the Arastradero Road site entrance. New four-foot sidewalks are proposed along the property edges and on the north side of the private road to improve pedestrian circulation, accessibility, and safety. The sidewalk along Old Trace Road was added in response to neighbor comments at the ARB hearing to further improve pedestrian safety. The City’s Office of Transportation has identified this area as a potential bicycle conflict zone and the proposed multi-modal circulation changes would improve conditions for both bicyclists and pedestrians.

Several residents either contacted staff or provided comments during the ARB and PTC hearing, expressing concerns about pedestrian safety along Arastradero Road, particularly highlighting the increased use of the corridor by school-aged children and older adults. The OOT had previously evaluated this intersection as a part of a separate analysis. At that time, additional crossing treatments were not warranted according to state standards (such as CA-MUTCD). For this project, staff applied engineering judgment to incorporate contextual considerations related to school routes and anticipated pedestrian activity associated with the proposed development. Based on these factors, staff find the project proposed improvement of a Rectangular Rapid Flashing Beacon (RRFB) at the existing marked crosswalk to be a beneficial safety measure along Arastradero Road as these devices increase driver yield compliance at crossings on roads with speed limits under 40mph.

ARB members requested that staff evaluate the feasibility of a STOP-controlled intersection in response to public comment. Upon review of the current expected traffic volumes and applicable warrant criteria, OOT staff does not recommend installation of a stop control device at this location; the RRFB is an appropriate traffic calming measure that is proposed to address the concerns about pedestrian safety raised by residents.

Trip Generation
The proposed subdivision would result in nine single-family residential parcels with nine primary residences and JADUs on seven of the nine lots. JADUs do not have an established trip generation rate in the Institute of Transportation Engineers (ITE) Manual because they generally function as an extension of the primary residence or as guest accommodations, with lower vehicle ownership and trip generation than primary dwellings. Therefore, the subdivision, which would develop one single-family residence on each resulting lot, is expected to increase net PM peak trips from zero to nine, as detailed in Attachment E. Even using a conservative assumption, the seven JADUs would generate approximately four additional PM peak hour trips, including two inbound and two outbound trips. However, pursuant to SB 54310, impact fees may not be imposed on ADUs of 750 square feet or less or on JADUs since they are always less than 500 square feet. Accordingly, no transportation impact fees would be required for trips attributed to the proposed JADUs, consistent with the conclusions derived in Attachment E.

FISCAL/RESOURCE IMPACT
Processing of this application has no fiscal impact, as the applicant is responsible for all staff and consultant costs through applicable fees established per the 2026 Municipal Fee Schedule.11 The project would be required to pay Development Impact Fees, currently estimated at $931,404.74, in addition to the applicable public art fee. Further, pursuant to PAMC Section 16.65.030(c), a housing in-lieu fee, currently estimated at $588,316.67, would be required for the fractional affordable housing unit. The parkland dedication fee must be paid prior to Final Map approval. All other fees associated with the streamlined development application would be due prior to issuance of building permits. Fees may be deferred to occupancy in accordance with PAMC Section 16.65.030(c) and State law.

STAKEHOLDER ENGAGEMENT
The Palo Alto Municipal Code requires notice of this public hearing be published in a local paper and mailed to owners and occupants of property within 600 feet of this subject property at least ten (10) days in advance. Notice of public hearing for this project was published in the Daily Post and postcard mailing occurred on May 8, 2026, which is 10 days in advance of the meeting.

Public Comments
At the ARB Study Session on March 5, 2026, approximately 20 members of the public commented on the project. Key comments included:
Lack of bicycle and pedestrian infrastructure along Old Trace Road. Congestion and queuing along the Old Trace Road and Arastradero Road intersection. Limited ingress and egress to and from Old Trace Road onto Arastradero Road with added traffic impact from the proposed development.
Emergency services access.
Potential construction impacts.
10 SB 543 Bill Text: Bill Text - SB-543 Accessory dwelling units and junior accessory dwelling units. 11 Link to 2026 Municipal Fee Schedule: Adopted Municipal Fee Schedule.book Several members of the public who attended the ARB Study Session were also present at the PTC hearing on April 29, 2026, and reiterated their concerns on the aforementioned topics. One concern raised at the PTC hearing was regarding the potential impacts on homeowners’ insurance as a result of the new development, a concern which was also voiced by several Commissioners. While staff cannot speak to the experience of individual public commenters, staff did reach out to an insurance agent for more insight into this statement and were informed that the proposed development should not have an impact on the availability of insurance on neighboring properties. The public also requested to stay involved in the naming of the private street which per City of Palo Alto Resolution 5739 requires a recommendation from the Palo Alto Historical Association (PAHA) and approval by Council prior to recordation of Final Map. Historically, PAHA has considered any names put forth by neighbors or developers.

However, in accordance with this resolution, PAHA selects and recommends a name for the street based on historical research of the area. Therefore, staff will convey any naming suggestions from the neighbors to PAHA, but no changes have been made to the City’s standard condition of approval.

Overall, members of the public urged the applicant and City staff to consider existing safety and accessibility conditions at this location, including the street right-of-way width and emergency vehicle access. The applicant has revised the Tentative Map to include transportation safety improvements listed above and is currently revising the proposed housing improvements based on feedback from the ARB as well as neighboring residents. The applicant has agreed to a tolling agreement for the Streamlined Housing Development Review application to extend the strict timelines imposed on the City by AB 130. This extension will allow for additional meaningful changes to address comments raised by members of the public and the ARB.

However, the applicant has not agreed to a tolling agreement for the Tentative Map.

All public comments received till date are included in Attachment D.

ENVIRONMENTAL REVIEW
The subject project has been assessed in accordance with the authority and criteria contained in CEQA, the State CEQA Guidelines, and the environmental regulations of the City. On January 25, 2026, the applicant requested that the project be considered exempt under AB 130 (Public Resources Code Section 21080.66). AB 130 exempts certain urban infill housing projects from CEQA and additionally sets strict timelines for City review and decision. Under California Government Code Section 55421 and the definitions of “urbanized area” and “infill site” pursuant to Public Resources Code (PRC) Sections 21094.5 and 21061.3, all properties within the City of Palo Alto are considered to be located in an urbanized area because they are within an incorporated city. While the City may adopt its own context definitions for planning and zoning purposes, those local definitions do not govern project eligibility under AB 130.

On February 4, 2026, following the applicant’s submittal of additional information and revised plans, the City determined that the project meets the definitions of “urbanized area” and “infill site” under the PRC sections referenced above and is exempt from CEQA pursuant to AB 130.

Accordingly, the City sent notification letters inviting tribes to participate in consultation on the project.

The City received one request for consultation from Tamien Nation and consultation was completed May 3, 2026. The City is required to make a decision on this project within 30 days following the completion of consultation, in accordance with the streamlined process timelines set forth in AB 130.

ATTACHMENTS
Attachment A: Location Map Attachment
Attachment B: Draft Record of Land Use Action
Attachment C: Zoning Consistency
Attachment D: Public Comments
Attachment E: Transportation Study
Attachment F: Project Description Letter
Attachment G: Project Plans
APPROVED BY:

Jonathan Lait, Planning and Development Services Director

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